JUDGMENT

Manmeet Pritam Singh Arora, J. (ORAL):

Review Petition 279/2022

1. The present application has been filed by Revenue seeking a review of the judgment dated 27th September, 2022, insofar as the judgment at paragraph 10 directs the Assessing Officer (`AO') to determine the date of issuance of the notice issued under Section 148 of the Income Tax Act, 1961, (the `Act') dated 31st March, 2021 and holds that such date of issuance is determined by the AO to be 31st March, 2021, to complete the reassessment proceedings within 12 weeks as per the procedure as it existed prior to the amendment.

2. Learned senior standing counsel for the Revenue states that though this Court by its order dated 24th March, 2022, was pleased to stay the assessment proceedings pursuant to the reassessment notices, the AO being unaware of the said order had passed the assessment order in this case on 26th March, 2022. He states that no recovery proceedings were initiated in furtherance of the said assessment order and they were kept in abeyance till further orders of this Court. He states that as per the AO, the impugned Section 148 notice had been issued on 31st March, 2021, and in this regard he s